New NGL Pipeline And Renewable Generation Interconnection Settlements Highlight FERC's Expanded Enforcement Focus

In Short

The Situation: Recent Federal Energy Regulatory Commission ("FERC") enforcement settlements—one involving a natural gas liquids ("NGL") pipeline's compliance with reporting requirements, the other a renewable generator's compliance with the grid interconnection process—reflect FERC's expansion of its enforcement focus.

The Result: FERC-regulated entities face investigation and enforcement action risk based on a broader scope of regulated activities than has historically been the case.

Looking Ahead: FERC-regulated entities should carefully evaluate whether their FERC compliance programs are broad enough to address the full scope of their regulated activities, as areas traditionally handled outside of the enforcement process now may be subject to investigations and civil penalties.